Telnas v. Commissioner of Social Security

Filing 12

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 10/11/2016 for the filing of the administrative record. Order signed by Magistrate Judge Erica P. Grosjean on 9/9/2016. (Rooney, M)

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PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration
MARCELO ILLARMO (MABN 670079)
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Defendant
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SHERRI RENEE TELNAS

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Plaintiff,
v.
CAROLYN W. COLVIN,
Acting Commissioner of Social Security,

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Defendant.

) Case No.: 1:16-cv-00583-EPG
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) STIPULATION AND ORDER FOR AN
) EXTENSION OF TIME
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IT IS HEREBY STIPULATED, by and between the parties, through their respective
counsel of record, that the time for responding to Plaintiff’s Complaint will be extended by 33
days, from September 8, 2016 until October 11, 2016.
This is Defendant’s first request for an extension of time to respond to Plaintiff’s motion.
Defendant respectfully requests this additional time because additional time is needed to prepare
the administrative record.
The parties further stipulate that the Court’s Scheduling Order (Dkt No. 5-1) shall be
modified accordingly:

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Stip. & Order for Ext.; 1:16-cv-00583-EPG

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Within thirty (30) days after service of the administrative record, on or before November
10, 2016, appellant shall serve on respondent a letter brief outlining the reasons why
he/she contends that a remand is warranted
Within thirty−five (35) days after service of appellant's letter brief, on or before
December 15, 2016, respondent shall serve a response to appellant's letter brief on
appellant.
In the event the parties stipulate to a remand to the Commissioner, the stipulation shall be
filed with the Court WITHIN fifteen (15) days after respondent serves his response on
appellant, on or before December 30, 2016.
In the event respondent does not agree to a remand, within thirty (30) days of service of
respondent's response, on or before January 16, 2017, appellant shall file and serve an
opening brief with the court and on respondent.
Respondent's responsive brief shall be filed with the court and served on appellant within
thirty (30) days after service of appellant's opening brief, on or before February 15, 2017.
Appellant's reply brief shall be filed with the court and served on respondent within
fifteen (15) days after service of respondent's brief, on or before March 2, 2017.

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Respectfully submitted,

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Dated: September 8, 2016

/s/ Steven G. Rosales
(*as authorized via e-mail on 09/06/2016)
STEVEN G. ROSALES
Attorney for Plaintiff

Dated: September 8, 2016

PHILLIP A. TALBERT
Acting United States Attorney
DEBORAH LEE STACHEL
Acting Regional Chief Counsel, Region IX
Social Security Administration

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By:

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/s/ Marcelo Illarmo
MARCELO ILLARMO
Special Assistant United States Attorney
Attorneys for Defendant

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Stip. & Order for Ext.; 1:16-cv-00583-EPG

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ORDER

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The Court approves the above parties’ stipulation, however, in addition to the listed

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deadline, the Commissioner shall file the administrative record no later than October 11, 2016.

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IT IS SO ORDERED.
Dated:

September 9, 2016

/s/
UNITED STATES MAGISTRATE JUDGE

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Stip. & Order for Ext.; 1:16-cv-00583-EPG

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